Duncan to revise of Class IV license application

The Ohio EPA is asking Portsmouth Wastewater Director Rick Duncan to provide additional information in order for the application for his 4th Class Operator’s License to be completed. It is Duncan’s third time trying for the license.

“The (Operator Certification Advisory) Council was concerned with the lack of detail and specificity in your discussion of the operation and process control of your facility,” the letter from Andrew Barienbrock, Environmental Supervisor of the Operator Certification Unit, Division of Drinking and Ground Water, said. “In order to alleviate these concerns, the Council would like you to take a course on Wastewater Process Control and Troubleshooting. Please provide a detailed syllabus for the course you are considering taking in order for the Council to review and approve the content prior to your taking the course.”

The committee is asking Duncan to provide a written discussion of the operation of his plant with respect to process control and troubleshooting, including a detailed discussion of a process control strategy as it applies to the Portsmouth plant - both wet stream and solids handling. The report is also expected to include a discussion of the need for analysis of process control parameters at the plant, as well as a discussion of plans to improve the level of treatment and final effluent quality at the plant. The report is also expected to include a discussion of the actual design flow and NPDES permit loading flow and reasons for the difference between the two and a discussion of the impact of side streams on the plant’s performance.

In addition, the report will be expected to include comparison of design versus actual hydraulic and organic loadings to the individual plant units, include a discussion of the impact of overloading or under loading on the performance of each unit among other information.

Duncan said the word “test” as it applies in the case of the 4th Class Operator’s License is a misnomer.

“It’s not a test,” Duncan said. “It’s a process where an applicant has to submit documentation of his experience and his qualifications to become licensed as a Class-4 operator.”

It is, in reality, an approximately 200-page document that describes Duncan’s background, the operation of the Wastewater Treatment Plant, collection system, the administration of the department, his entire career as an engineer and an operator.

He submitted his second revision, about 20-30 pages in March, and expects the plan they are asking for to be approximately another 20-30 pages.

Duncan said it is unusual for operators to be approved the first time around.

“When I did mine (Class-IV), they asked me for an addendum. They wanted some more information,” Portsmouth Water Treatment Director Sam Sutherland (a Class-IV operator) said. “I might have been a little light on the planning section of it. There were a couple of little issues. But I submitted that information and after they got it, everything was straight. They awarded it to me.”

Duncan said he was hopeful for approval, but will take the necessary steps requested of the Council.

“I was hoping to be approved in my second submittal, and they said my application was fine. They just wanted additional information to back it up,” Duncan said. “So, because I’m an engineer and don’t have the background of an operator, they have asked me to take a correspondence course and to develop a plan to make some improvement in our plant operations.”

Duncan said his understanding is, based on a meeting he had with the committee on May 16, 2013, that they would be sending him a letter with the additional requirements they were seeking.

“My understanding, based on that meeting and the letter, is that if I send them this remaining information, that they are very likely to approve my application at that time,” Duncan said.

The letter goes on to say, “Your next submittal will be your third and final opportunity to pass your Class IV. In the event the information does not address the questions above, the Council may recommend failure of the examination.”

Duncan clarified the application process further.

“Their policy is that if you don’t pass by your second revision, which would be the third step - you have to start restart the application process,” Duncan said. “That doesn’t really take any extra time, you just have to re-submit your paperwork. And that just keeps them from having to send something back multiple times. So it is their policy - they don’t give you a chance to do a third revision, but you just have to start all over.”

Duncan said he scored in the 90s on his Class-III test. For the Fourth Class, there are two four-member boards - a four-member board for water treatment and a four-member board for wastewater treatment, and that board is made up of a mixture of engineers and operators, and those committees only review up to three applications per month.

Duncan said one of the reasons it has taken so long to get the license is his workload. He is the lone administrator of that department and has been working on flood defense issues, the Long Term Control Plan, administrative order, property acquisition, as well as the day-to-day operation of the actual physical plant. Duncan has asked City Council for another administrator to help with some of the projects, but was rejected.

Duncan said he believes there are less than 200 Class-IV wastewater operators in Ohio, and many are already retired.

“I feel very positive about it,” Duncan said. “It has been a long process. I’m looking forward to getting it over.”

Frank Lewis may be reached at 740-353-3101, ext. 252, or at flewis@civitasmedia.com. For breaking news, follow Frank on Twitter @FrankLewisPDT.

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